Sign Up Terms & Conditions

Website Terms and Conditions

I. ABOUT THESE TERMS AND CONDITIONS

Your Use of This Website

These terms and conditions, together with the documents or Website pages referred to in the
terms and conditions (the “Terms and Conditions”), apply to the
Website home page (the
“Website”).

All visitors to or users of this Website are referred to as
“Members”, “you” or similar terms.

By clicking to accept or agree to these Terms and Conditions, you are acknowledging that you
have read, accepted and agreed to be bound by the Terms and Conditions, including our
Privacy and Cookie Policy,
and you are therefore advised to read these Terms and Conditions and our Privacy and Cookie
Policy carefully before proceeding to use the Website and before providing any data to us. If
you do not agree to these Terms and Conditions or our Privacy and Cookie Policy you must not use
this Website or create a personal account on the Website
(an “Account”).

Any violation of these Terms and Conditions may lead to termination of your Account,
cancellation of any credit on your account (“Cash”, as defined more
fully in clause VII of these Terms and Conditions) or other items earned or accrued including
referrals, as well as any other applicable legal remedy.

About Us

This Website is owned and operated by InboxPounds Limited
(“InboxPounds®”, “us”,
“we” or similar terms) registered in England and Wales under
company number 07871672 and with registered address 3rd Floor, 1 Ashley Road,
Altrincham, Cheshire, WA14 2DT. InboxPounds® is a subsidiary of CotterWeb Enterprises,
Inc., a corporation registered in the United States of America.

About the Website

The Website provides visitors with a means of access to offers from a range of third party
advertisers, including those offering insurance, travel, finance, utilities and on-line
gambling. We do not supply any products or services you may access via the Website – all
products and services are provided by, and purchased from, independent third party sites (even
where these may be co-branded with InboxPounds®) to which you navigate via the Website
(“Advertised Sites”). Purchases from Advertised Sites will be
subject to the terms and conditions of the third party product/service provider, which you are
advised to read carefully before concluding your purchase.

Nothing within the Website is, or shall be deemed to constitute, financial or other advice or a
recommendation to purchase any product or service. Any and all information provided within the
Website is for general information purposes only.

Reservation of Rights

We reserve the right to modify these Terms and Conditions at any time. Such changes, including
retroactive changes, are effective once posted on this or a similar page of our Website. Changes
may include, but are not limited to, rules regarding the earning of Cash and the redemption of
Cash or any other item. Pages or features of this Website as well as offers appearing on this
Website, including prizes, gifts, sweepstakes, offers, or other items or activities may be
discontinued or changed without notice (“Offers” as more fully
defined in Section VI below).

If such changes are made, your continued use of the Website will be deemed to constitute your
acceptance of the amended Terms and Conditions. You are expected to check this page of the
Website from time to time to take notice of any changes made, as they are binding on you.

We reserve the right to remove any material or posting you make on the Website if, in our
opinion, such material does not comply with the content standards which we set for the Website.

We reserve the right to suspend or curtail your access to the Website at any time without notice
including making certain parts of the Website unavailable at our discretion.

Changes to the Privacy and Cookie Policy will be made in accordance with the terms of the
Privacy and Cookie Policy

Viruses, Hacking and Other Offences

You must not misuse our Website by knowingly introducing viruses, trojans, worms, logic bombs or
other material which is malicious or technologically harmful. You must not attempt to gain
unauthorised access to our Website, the servers on which our Website is stored or any server,
computer or database connected to our Website. You must not attack our Website via a
denial-of-service attack or a distributed denial-of service attack.

By breaching this provision, you would commit a criminal offence under the Computer Misuse Act
1990. We will report any such breach to the relevant law enforcement authorities and we will
co-operate with those authorities by disclosing your identity to them. In the event of such a
breach, your right to use our Website will cease immediately.

We will not be liable for any loss or damage caused by a distributed denial-of-service attack,
viruses or other technologically harmful material that may infect your computer equipment,
computer programs, data or other proprietary material due to your use of our Website or to your
downloading of any material posted on it, or on any website linked to it.

II. MEMBERSHIP

Valid Information

Members must be living individuals, and not corporations or any other type of entity. Members
must provide a valid e-mail address during registration in order to activate their Account. The
country listed in your personal member profile associated with your Account
(“Member Profile”) must be the country you are both living in, and
logging into your Account from. In addition, any time you provide information to this Website,
to any advertisers on the Website (“Advertisers”, as more fully
defined in Section VI), or in response to any Offer, such information must be accurate and
complete and be your own information and not the information of any other person. This includes,
but is not limited to, the registration process, Profile Surveys, and any other place where
information is requested.

Any personal data you provide to us will be used only in ways that are fair and in accordance
with these Terms and Conditions and the terms of our
Privacy and Cookie Policy.

Comply with Laws

Members must comply with all applicable laws and regulations as they relate to the use of this
Website or relations with us.

Duplicate Accounts

Members may not create more than one Account with the Website. In addition, we do not
allow:

More than one Account in the same household

More than one Account with the same mailing address

More than one Account using the same computer

Signup Bonus

Upon the creation of an account, a member will earn an initial Cash earnings, which will be
credited to their Account as described in other sections of these Terms and Conditions
(“Signup Bonus”). To qualify for the Signup Bonus, Members must
sign up and activate their Account.

Account Cancellation

Members may cancel their Account any time by clicking the “Cancel Account” link in
the “My Account” tab. In addition, all PaidEmails™ sent to Members
include a link to the cancellation page. If a Member cancels their Account, they will forfeit
all their Cash in their Account and referrals. In addition, any requested or pending payments
for that Member are removed and forfeited.

Password and Account Security

In connection with your Account, you will create a personal password
(“Password”). You are responsible for keeping your Password
confidential and secure, and you are responsible for all actions taken using your Password.

Age

To create an Account, to be eligible to accrue Cash, or to otherwise use this Website, you must
be at least eighteen (18) years old.

Current and Accurate Contact Information

Members are responsible for maintaining accurate and complete contact information and promptly
updating such information if they move, their contact information otherwise changes, or if a
Member has difficulty receiving emails from InboxPounds® at the e-mail address provided.
If a payment posted to a Member is returned to us for any reason, including our being provided
with inaccurate or outdated contact information, we will hold such payment for up to ninety (90)
days and will resend the payment upon request and receipt of correct contact information within
the ninety (90) day period. If we do not receive a request to resend payment along with correct
contact information within ninety (90) days, then we will destroy the cheque, all Account Cash
giving rise to the payment will be deemed forfeit, and the payment is forfeited and permanently
waived. (“Cash”, as defined more fully in clause VII of these Terms
and Conditions)

Delivery Location

Members are responsible for selecting a secure and reliable mail delivery address for their
payments and other communications. We are not responsible for any stolen or lost cheques and
will not replace cheques allegedly cashed improperly by third parties so long as such cheque was
sent to the mailing address as indicated in your Account information at the time such cheque was
sent. If your household postbox is not secure, we recommend you obtain a secure post office box.

Code of Conduct

By agreeing to these Terms, you're agreeing that you will also follow these rules: (1) Do not
publicly display or use the Website or features to share inappropriate Content or material
including but not limited to; nudity, pornography, graphic violence, use harassing or hate
comments to employees of the Website and/or its members. This includes the Website and all forms
of social media (Facebook, Twitter, Instagram etc.). Failure to comply may result in the loss of
account and earnings. (2) You are responsible for all usage on your Account, whether or not
authorized including your log in, password and Account information.

III. REFERRALS

Tracking

Members can use their Referral URL to refer other Members to the Website. Because
InboxPounds® allows only one Account per computer, our referral tracking software will
not allow one Member to refer another Member if they are using the same computer.

Spam and Unsolicited Email

Members may not send unsolicited email to persons they do not know in order to refer other
Members to the Website and may only forward emails to people they know would be happy to receive
them. We cannot possibly list all acceptable and unacceptable methods of advertising. If a
Member has a specific question as to whether or not a particular advertising method is
acceptable, they should contact us (using the Contact Us page) prior to engaging in that
action.

Members may not send unsolicited e-mail (e-mail that has not been actively invited by the
recipient) advertising InboxPounds® or the Website.

Members may send solicited e-mail (e-mail that has been actively invited by the recipient)
to their subscribers or friends advertising InboxPounds® or the Website. However,
Members must adhere to all applicable, current legislation and regulations, including the
provisions of the Privacy and Electronic Communications (EC Directive) Regulations 2003 (as
amended). Further guidance on the provisions of this legislation is available at the
Information Commissioner’s Office website.

Refer-a-Friend Service

Members may use our Refer-a-Friend Service to automatically send an e-mail notification to their
friends. However, if the Member’s Refer-a-Friend e-mail results in a complaint, the
Member’s Account may be terminated. You should use the Refer-a-Friend Service to notify
only your close personal friends, where you know that the friend will be happy to receive the
e-mail notification.

False Advertising and Testimonials

Members may not make untrue or exaggerated statements when advertising InboxPounds® or
engage in any unfair or deceptive trade practice as defined by law. For example, a Member may
not put on their website: “Join InboxPounds® and get paid
£1.00 for every Email you read!” If the Member provides
information about InboxPounds® on their website, they must ensure the information is
updated and accurate. A Member’s Account may be terminated for false advertising.

You must be especially careful to obey applicable laws and regulations regarding testimonial or
endorsement by you recommending InboxPounds®, an Advertiser or Offer, so that such
testimonial or endorsement is not false or misleading. For example, if you made an online
statement recommending InboxPounds®, then you should also disclose the material
connection between yourself and InboxPounds®.

Referral Rewards

Members will be instantly credited 10% of all Qualified Earnings generated by Members they refer
to InboxPounds®. There is no limit to the amount of referrals you can have or the amount
of cash you can earn from your referrals. Qualified Earnings are defined within the
InboxPounds® Knowledge base

IV. INACTIVITY

A Member’s Account may be set to inactive for any of the following reasons:

Invalid Email Address

If InboxPounds® receives a bounce-back error message or similar message when sending
an e-mail to you, then your Account will be set to inactive. A bounce-back message may occur
if you have added InboxPounds® to your “Ignore List” or marked a message
from InboxPounds® as spam, or for other reasons. You should add the address
paidemail@inboxpounds.co.uk to your e-mail “Allow List”
and/or “Address Book”.

Failure to Remain Active

If you do not visit our website while being logged in or confirm at least one
PaidEmail™ in a 10-day period, your Account may become inactive.
InboxPounds® reserves the right to change this number at any time.

Payment Requests

Payment Requests are removed if a Member’s Account becomes inactive. The automated
system that deactivates Members based on the above criteria runs immediately prior to
Payment Requests being processed. Therefore, it is possible for a Member’s Account to
be active right up until their payment is processed. InboxPounds® urges Members to
ensure their Account remains active in order to avoid any delay in processing payments.

Reactivation

If your Account becomes inactive, you can reactivate it within 6 months of the Account being
placed on inactive status by logging into the Member’s Section and requesting a
confirmation e-mail be sent to you. When you click the link provided in the confirmation
e-mail, your Account will be reactivated.

V. PERMANENT REMOVAL

If you do not visit our Website while being logged in or confirm a PaidEmail™ at least
one time in a 6-month period, your Account will be permanently removed and all Cash or other items
accrued will be forfeited. In the event of the death of any Member, such Member’s Account is
automatically and immediately terminated, and all Cash or other items accrued in such Account are
forfeited.

VI. CASH EARNING ACTIVITIES

InboxPounds® has established relationships with advertisers and partners (collectively,
“Advertisers”) to provide Members with a variety of ways to earn cash
(“Cash Earning Activity/Activities” or
“Offers”). Cash Earning Activities are made available to Members based
on a variety of factors, including demographic information, physical location, and participation
level with InboxPounds®. InboxPounds® and our Advertisers make no guarantees
regarding the number or amount of Cash Earning Activities that will be available to Members at any
time.

Participation

When a Member completes an Offer through the Website, they are creating a direct
relationship with the Advertiser who provided the Offer. Members should review the
Advertiser’s terms and conditions relating to the Offer prior to completing the Offer.
InboxPounds® assumes no liability, obligation, or responsibility for any Offer on
our Website, or for any subsequent billing or relationship that occurs between Member and
Advertiser. Members should contact the Advertiser directly if they have any questions or
disputes relating to the Offer.

Some Offers provide additional incentives, such as gift cards, for completing the Offer. In
these cases, the incentive is provided directly by the Advertiser to the Member, and is
independent of the InboxPounds® program. There may be additional requirements to
receive these incentives beyond what is required to receive credit from
InboxPounds®. InboxPounds® is not responsible for these additional
incentives.

Completion of Offers/Cash Earning Activities

Unless otherwise stated, Offers are available for first-time customers only. Members will
not be credited for completing an Offer if they have completed the Offer in the past,
through the Website, any other website, or with the Advertiser directly.

To be credited for completing an Offer, Members should complete the Offer immediately after
clicking the Offer on our Website or in a PaidEmail™. Returning to the
Advertiser’s website at a later time to complete the Offer or completing the Offer
over the phone may result in not being credited for completing the Offer.

The tracking and crediting of Offer completions is done via cookies (for a description of
what cookies are and how they operate, please see our
Privacy and Cookie Policy).
Members should ensure their web browser is set to allow all cookies in order to be properly
credited for Offers they complete. In addition, Members should ensure their anti-virus
and/or anti-spyware software does not automatically override their web browser’s
cookie settings. For more information on our use of cookies, and your options in respect of
cookies, please see our
Privacy and Cookie Policy.

Crediting of Offers/Cash Earning Activities

Most Offers will be credited to the Member’s Account within a few business days from
completion, while others may take up to 30 days to credit. Members should read and comply
with all requirements of an Offer to ensure timely credit.

InboxPounds® credits Members for completing Offers based on information we receive
from our Advertisers. Thus, the Advertiser has the final say in whether or not a Member is
credited for completing an Offer. InboxPounds® makes no guarantee that Members will
receive credit for completing an Offer. Members should save all confirmation/welcome emails
(and similar information) they receive from the Advertiser after completing an Offer. This
information can often be used to credit a Member’s account if this has not happened
automatically.

Many Offers on InboxPounds® include a free trial period that enables the Member to
try the product or service risk-free. Members should only complete these Offers if they have
a genuine interest in the product or service. Cancelling a free trial immediately after
joining may result in not being credited for completing the Offer. InboxPounds®
reserves the right, in our sole discretion, to terminate a Member’s account and
forfeit all earnings and referrals, in addition to any other legal remedies, in the event a
Member’s activity appears fraudulent.

VII. CASH AND PAYMENT

About Cash in Your Account

You can earn Cash which is credited to your Account as described in the other sections of these
Terms and Conditions, and which is subject to your compliance with all Terms and Conditions.
Your Account, including any Cash or other credits in your Account, is non-transferable and
non-assignable, and may not be pooled, lent, sold, or exchanged. We may change rules about
requesting Cash payment or redeeming other credits in your Account at any time and such changed
rules will apply to Cash already accrued as well as to Cash accrued in the future. You may
request Cash payment out of your Account (also referred to as “redeeming” Cash) only
as permitted by these Terms and Conditions. Redeeming Cash and receipt of any payment by you is
contingent upon your: (1) full compliance with these Terms and Conditions; and (2) compliance
with the specific rules or terms then in effect for the particular redemption offer.

You may not redeem Cash until you have accrued at least twenty pounds
(£20.00) in your account (the “Minimum Payment Amount”)
or such other amount as may be designated by us. The terms “Cash”,
“Pounds” and similar terms are used interchangeably in this Website to mean any and
all sums attributed to your Account. You have no right to redeem the Cash in your Account, and
we have no liability or obligation to pay you whatsoever, unless and until you have accrued at
least the Minimum Payment Amount in your Account. Unless and until you have accrued the Minimum
Payment Amount, such Cash is deemed a contingent liability, which is entirely contingent upon:
(1) your accrual of at least the Minimum Payment Amount in your Account, and (2) your full
compliance with these Terms and Conditions. Unless and until your Account balance reaches the
Minimum Payment Amount, the Cash in your Account has no cash value.

For example, if you open an account with an initial balance of 1 pound
(£1.00), and then accrue another fourteen pounds
(£14.00) in cash in that account, giving a total of
£15.00, you are not eligible to receive any payment, and we are not
liable to you for any amount. In this example you would have to earn yet another five pounds
(£5.00), giving a total of twenty pounds
(£20.00) accrued balance, before you would be entitled to any
payment.

Currently, the Minimum Payment Amount required to request a cheque payment is
£20.00; however, this amount may change from time to time.

Requesting Payment

You can request payment of the Cash in your Account, subject to the remainder of these Terms and
Conditions, by clicking the “Request Payment” link under the
“My Account” tab. As noted above, you may not request payment and the Cash in your
Account has no actual cash value until you have accrued at least the Minimum Payment Amount. A
description of each payment request method will be displayed, and if the Member’s Account
balance is large enough, a link to request that method of payment will also be displayed.
Members may have only one pending payment request at a time.

Tax Matters

You are responsible for any and all tax liability arising from or associated with your use of
this Website, including liability arising from your accrual of Cash or your redemption of Cash
for cash or other items.

Payment Schedule

Requests to redeem Cash and send payments are processed on the first Wednesday that occurs at
least 8 days after the payment was requested. This means payment requests will be processed
between 10 and 16 days after request. After requesting payment, Members can view their scheduled
payment processing date by clicking the “My Profile” link under the
“My Account” tab.

Payments are processed on Wednesday of every week and generally posted within 3 days, depending
on holidays and how many payment requests there are for that week.

All payments are inspected immediately prior to processing. Payment requests belonging to
Members who have become inactive (as described above in Section IV) or who have duplicate
Accounts will not be processed and will be removed.

Returns and Reversals

Any time you return a purchased item for which you received Cash in your Account, and any time
you void, cancel, rescind, or reverse any Cash shopping transaction for which you received Cash
in your Account, InboxPounds® may subtract a corresponding amount of Cash from your
Account. Similarly, if any Advertiser notifies us that it is reversing its transaction with you
for any reason on any of our Cash Earning Activities, we will subtract a corresponding amount of
Cash from your Account. A pattern of completing Offers followed by reversals is considered
fraudulent activity, and may result in the termination of your Account and forfeiture of your
Cash earnings and referrals.

Fraud Prevention

InboxPounds® reserves the right to request further information from Members to ensure
they have not fraudulently completed Offers. This information may include, but is not limited
to, a copy of the credit card statement that was used to complete the Offers, in order to ensure
a stolen credit card was not used.

InboxPounds® reserves the right to place any payment request on hold, for any reason,
until the requested information has been provided by the Member. Ample notice will be given to
the Member to provide this information. If the Member does not provide this information before
their payment is scheduled to be processed, their Account will be suspended until they do so.
All decisions by InboxPounds® regarding fraud or suspected fraud are binding and final.

VIII. GENERAL TERMS

Copyrights and Trademarks

All content, materials, images, and other items on or accessed directly through this Website
(collectively, the “Content”) belong to InboxPounds®, its third party
licensors, or third party Advertisers. There are some important rules about using and copying
the Content. You may download or print one copy of the Content on this Website, but only for
your personal, non-commercial use. When you download or print a copy of the Content, you must
also include all copyright and other notices that are in the Content, including the copyright
notice on the bottom of the page.

The Content is protected by English as well as foreign copyright laws. If you use the Content in
a way that is not clearly allowed by these Terms and Conditions, you are violating your
agreement with us and may be violating copyright, trade mark, and other laws. In that case, we
automatically revoke your license to use the Content and you must immediately destroy any copies
you have made. All right, title, and interest in and to the Content remains with
InboxPounds® or our third party licensors. All rights not expressly granted are
reserved.

Notice of Infringing Images or Content: DMCA Notice

If you believe in good faith that any photos, images, text, or other Content appearing on this
Website infringes any copyright or other intellectual property right owned by you, please send a
Notice to:

Notice. The notice must include the following information: (a) a
physical or electronic signature of a person authorized to act on behalf of the owner of an
exclusive right that is allegedly infringed; (b) identification of the copyrighted work (or
other intellectual property right) claimed to have been infringed; (c) identification of the
material that is claimed to be infringing or the subject of infringing activity; (d) the name,
address, telephone number, and email address of the complaining party; (e) a statement that the
complaining party has a good faith belief that use of the material in the manner complained of
is not authorized by the copyright owner, its agent or the law; and (f) a statement that the
information in the notification is accurate and, under penalty of perjury, that the complaining
party is authorized to act on behalf of the owner of an exclusive right that is allegedly
infringed. If US law requires any additional or different procedure, then the terms of such law
shall control.

Linking to the Website

You may link to the home page of the Website, provided you do so in a way that is fair and legal
and does not damage our reputation or take advantage of it, but you must not establish a link in
such a way as to suggest any form of association, approval or endorsement on our part where none
exists.

You must not establish a link from any website that is not owned by you.

Our Website must not be framed on any other site, nor may you create a link to any part of our
Website other than the home page. We reserve the right to withdraw linking permission without
notice, and may do so where the website from which you are linking fails, in our opinion, to
comply with the content standards which we set for the Website.

If you wish to make any use of material on our Website other than that set out above, please
address your request to us at our Contact Us page.

Links from the Website

Where the Website contains links to other sites and resources provided by third parties, these
links are provided for your information and convenience only. We have no control over the
contents of those sites or resources, and accept no responsibility for them or for any loss or
damage that may arise from your use of them. Your use of other websites is subject to the terms
and conditions of those websites, including the privacy policies of those websites.

Limitation of Liability

To the extent permitted by law, you agree that neither InboxPounds®, nor any person
or company associated with InboxPounds®, including Advertisers or third party
suppliers (collectively, the “Covered Entities”) shall be
liable for any damage resulting from your use or inability to use this Website or the
materials on this Website.

To the extent permitted by law, the Covered Entities hereby expressly exclude:

All conditions, warranties and other terms which might otherwise be implied by
statute, common law or the law of equity,

Any liability for any direct, indirect or consequential loss or damage incurred by
any user in connection with our Website or in connection with the use, inability to
use, or results of the use of our Website, any websites linked to it and any
materials posted on it, including:

Loss of income or revenue;

Loss of business;

Loss of profits or contracts;

Loss of anticipated savings;

Loss of data;

Loss of goodwill;

Wasted management or office time; and

whether caused by tort (including negligence), breach of contract (including
fundamental breach) or otherwise, even if foreseeable, provided that this
condition shall not prevent claims for loss of or damage to your tangible
property or any other claims for direct financial loss that are not excluded by
any of the categories set out above.

The total liability of Covered Entities for losses, damages, or claims of any kind shall be
limited to the amount of your actual damages, not to exceed the greater of
£250 or the amount of Cash in your account at the time the
claim arises. In no event shall the Covered Entities be liable to you for any losses or
damages other than the amount described above.

The limitation of liability in this clause does not affect our liability for death or
personal injury arising from our negligence, nor our liability for fraudulent
misrepresentation or misrepresentation as to a fundamental matter, nor any other liability
which cannot be excluded or limited under applicable law.

Exclusion of Warranty

All content on this Website is provided to you on an “as is”
“as available” basis without warranty of any kind either express or implied.

InboxPounds® makes no warranty as to the accuracy, completeness, currency, or
reliability of any content available through this Website, including but not limited to the
offers provided by Advertisers. You are responsible for verifying any information before
relying on it. Use of the Website and the content available on the Website or linked to by
the Website is at your sole risk.

InboxPounds® makes no representations or warranties that use of the Website will be
secure, uninterrupted or error-free. You are responsible for taking all necessary
precautions to ensure that any content you may obtain from the Website or from linked
websites is free of viruses or similar destructive programs.

To the extent permitted by law, you agree that InboxPounds® shall not be liable for
any claim or damages related to any loss, destruction, or alteration of data related to your
use of the Website. The foregoing disclaimer includes but is not limited to reliance by you
or any third party on any content or information obtained through the use of the Website, or
any damage or harm resulting from any mistakes or omissions in, or delays in transmission
of, information to or from the Website, interruptions in telecommunications connections to
the Website, or viruses, whether caused in whole or in part by negligence, acts of god,
telecommunications failure, theft or destruction of, or unauthorised access to the Website,
or related information or programs.

Indemnity

You agree to indemnify, defend and hold the Covered Entities described above harmless from and
against any and all costs, liabilities, losses, and expenses (including, but not limited to,
reasonable legal fees) resulting from any claim, suit, action, or proceeding brought by any
third party against any of the Covered Entities alleging or arising from or related to your use
of the Website or any breach of these Terms and Conditions by you. This paragraph survives
expiration or termination of your Account, your membership or these Terms and Conditions.

Independent Parties

You and InboxPounds® are independent parties as to one another. You are not
InboxPounds’ agent or employee for any purpose and shall not hold yourself out as
InboxPounds’ agent or employee.

Contact Us

Our contact information is available at the Contact Us page.

Members seeking support for their Account should login to the Member’s Section and click
the “Support Centre” link.

Governing Law and Jurisdiction

The English courts will have non-exclusive jurisdiction over any claim arising from, or related
to, a visit to or use of our Website although we retain the right to bring proceedings against
you for breach of these Terms and Conditions in your country of residence or any other relevant
country.

These Terms and Conditions and any dispute or claim arising out of or in connection with them or
their subject matter or formation (including non-contractual disputes or claims) shall be
governed by and construed in accordance with the law of England and Wales.

Limitation on Claims

You agree that in the event you have or may have any alleged claim against InboxPounds®
or any of the Covered Entities, you shall pursue such claim only in your individual capacity,
and you shall not agree to join or be a part of any class action, consolidated action, or
similar action. You also agree that your damages are limited as set forth elsewhere in these
Terms and Conditions and that you are not eligible to receive, and shall not seek, legal fees in
relation to any claim you have or may have against InboxPounds® or any of the Covered
Entities.

Third Party Rights

To the extent that the provisions of clauses VIII.5, VIII.6, VIII.7 and VIII.11 provide
rights for the benefit of persons that are not parties to these Terms and Conditions, the
parties agree that these rights are enforceable third party rights, validly exercisable by
any person identified by the description set out in Clause VIII.5 as the definition of
Covered Entities.

Except as expressly provided elsewhere in these Terms and Conditions, a person who is not a
party to these Terms and Conditions shall not have any rights under the Contracts (Rights of
Third Parties) Act 1999 to enforce any of the terms of these Terms and Conditions. This does
not affect any right or remedy of a third party which exists or is available apart from that
Act.

Miscellaneous

If any provision of these Terms and Conditions is held to be overbroad, invalid, or
unenforceable, such provision shall be deemed amended to the minimum extent necessary to
render such provision valid and enforceable. If any provision cannot reasonably be deemed
amended, then such provision shall be struck and the remaining provisions shall be enforced.

Headings are for reference purposes only and in no way define, limit, construe or describe
the scope or extent of such section.

Members may not sell, assign, or otherwise transfer any rights under these Terms and
Conditions, including any membership, Cash, or other benefit. InboxPounds® may
assign or transfer its rights and obligations under these Terms and Conditions.

Our failure to act with respect to any failure by you or others to comply with these Terms
and Conditions does not waive our right to act with respect to subsequent or similar
failures.

These Terms and Conditions, along with any changes or updates thereto by us as described
above, set forth the entire understanding and agreement between us with respect to the
subject matter hereof. All sections of these Terms of Use, other than those sections dealing
with your future accrual of Cash, survive expiration or termination of your Account or your
right to use or visit this Website for any reason.

x

Sign Up Privacy Policy

Welcome to InboxPounds® Limited’s Privacy and Cookie Policy

InboxPounds® Limited respects your privacy and is committed to protecting your personal data.
This Privacy and Cookie Policy will inform you as to how we look after your personal data when you visit
our website (regardless of where you visit it from) and tell you about your privacy rights and how the
law protects you.

This Privacy and Cookie Policy is provided in a layered format so you can click through to the specific
areas set out below.

I. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this Privacy and Cookie Policy

This Privacy and Cookie Policy aims to give you information on how InboxPounds® Limited
collects and processes your personal data through your use of this website, including any data
you may provide through this website when you sign up and create an account with us or take part
in any of our great prizes, games, offers, surveys and competitions (Offers).

This website is not intended for children and we do not knowingly allow children to create a
members account or profile on the website.

It is important that you read this Privacy and Cookie Policy together with any other privacy
notice or fair processing notice we may provide on specific occasions when we are collecting or
processing personal data about you so that you are fully aware of how and why we are using your
data. This Privacy and Cookie Policy supplements the other notices and is not intended to
override them.

Who is InboxPounds® Limited?

InboxPounds® Limited is a company registered in England and Wales which owns and
operates this UK website and collects your data through and in relation to it.

The operation of this website and the associated activities of InboxPounds® Limited in
relation to its UK members are governed by the UK data protection authority, the Information
Commissioner’s Office (ICO). InboxPounds® Limited is registered with and
pays all applicable fees to the ICO. Our registration number is Z2994933. You have the right to
make a complaint at any time to the ICO, the UK supervisory authority for data protection
issues, whose website and contact information can be found at www.ico.org.uk. The phone number to contact the ICO is 0303 123 1113. We
would, however, appreciate the chance to deal with your concerns before you approach the ICO so
please contact us in the first instance.

We have appointed a data protection officer (DPO) who is responsible for overseeing
questions in relation to this Privacy and Cookie Policy. If you have any questions about this
Privacy and Cookie Policy, including any requests to exercise your legal rights, please contact
the DPO using the contact details set out below.

InboxPounds® Limited’s contact details are:

Full name of legal entity: InboxPounds® Limited

Name or title of DPO: Chief Technical Officer, Tom Healy

Email address: dpo@inboxpounds.co.uk

Telephone number: 651 289 0720

Who is CotterWeb Enterprises Inc. and why is InboxPounds® Limited sharing data with
them?

Many of InboxPounds® Limited’s operations are supported by website servers located
in the United States under the control of its US parent company, CotterWeb Enterprises Inc.,
details of which can be found here. As a result, InboxPounds® Limited will transfer your data
outside the European Economic Area (EEA) to its parent company, CotterWeb Enterprises Inc. in
the United States and these two companies together are regarded as joint controllers in relation
to the personal data received through and in relation to this UK website. This Privacy and
Cookie Policy is issued on behalf of both companies and so when we mention
“InboxPounds®”, “we”, “us” or
“our” in this Privacy and Cookie Policy, we are referring to both
InboxPounds® Limited and CotterWeb Enterprises Inc. as joint controllers responsible for
processing your data, unless we clearly indicate otherwise by using either company’s full
registered name.
See the section on Privacy Shield certification at section 12 below to see how
CotterWeb Enterprises Inc. is also protecting your data protection rights.

Changes to the Privacy and Cookie Policy and your duty to inform us of changes

This version was last updated on April 31, 2019 and historic versions can be obtained by
contacting us. We may make changes to this Privacy and Cookie Policy at any time. You can always
access the most up to date version here or by clicking on a link to
the Privacy and Cookie Policy on our website.

It is important that the personal data we hold about you is accurate and current. Please keep us
informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on
those links or enabling those connections may allow third parties to collect or share data about
you. We do not control these third-party websites and are not responsible for their privacy
statements. When you leave our website, we encourage you to read the privacy notice of every
website you visit.

II. THE DATA WE COLLECT ABOUT YOU

About Personal Data

Personal data, or personal information, means any information about an individual from which
that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have
grouped together follows:

Member Identity Data includes [first name, last name, username or similar identifier
and login password].

Member Reward Payment Data includes [name, residential address and amount of
member’s reward if receiving payment by cheque or by pre-paid master card or name and
associated Paypal account email if receiving payment by Paypal].

Transaction Data includes [details about reward payments made to you and other
details of your interactions with us including Offers completed by you or referrals of other
members that you have introduced to InboxPounds®].

Technical Data includes [internet protocol (IP) address, your login data, browser
type and version, time zone setting and location, browser plug-in types and versions,
operating system and platform and other technology on the devices you use to access this
website].

Usage Data includes [information about how you use our website, product and
services].

Marketing and Communications Data includes [your preferences in receiving marketing
from us and third parties and your communication preferences].

Personal data can be anonymised or pseudonymised, which means ensuring that when it is processed
it either no longer includes any identifying elements or has those elements replaced with a
value like a number from which an individual cannot be identified (Anonymous Data).
Personal data can be considered to be Anonymous Data either on a temporary basis, because we
still hold the means to re-associate it with your information from which you are personally
identifiable, or on an irreversible basis by us destroying or irretrievably removing the
identifying elements entirely so they cannot be re-associated in future. We will sometimes use
your data in a form which is Anonymous Data as part of our security measures to minimise the
risk of it being used to in an unauthorised way whilst being processed.

We also collect, use and share Aggregated Data such as statistical or demographic data
for any purpose. Aggregated Data may be derived from your personal data, but is not considered
personal data in law as this data does not directly or indirectly reveal your identity. For
example, we may aggregate your Usage Data to calculate the percentage of users accessing a
specific website feature. However, if we combine or connect Aggregated Data with your personal
data so that it can directly or indirectly identify you, we treat the combined data as personal
data which will be used in accordance with this Privacy and Cookie Policy.

We do not collect any Special Categories of Personal Data about you (this includes
details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual
orientation, political opinions, trade union membership, information about your health and
genetic and biometric data). Nor do we collect any information about criminal convictions and
offences.

Member Referrals

You may also give us the personal data of a name and email address for someone else who you want
to refer to our website and services (a Member Referral) because by making a Member
Referral you can earn additional rewards to your Member account. If you do provide us with a
Member Referral it is important, firstly that you get that person’s permission to give
their personal data to us and make sure they understand this means we will be sending them email
communications to provide them with a link to our website and Offers. Secondly, you should point
them to this Privacy Policy so they can understand how we might use their personal data if they
do choose to become a member and have their own account with us. If a person creates a
membership account with us following a Member Referral by you, we will use the Member Identity
Data and our cookies (see Cookies section below) in order to
verify their registration matches the data you provided for the Member Referral so that you get
correctly credited for that Member Referral resulting in a new member registration on our
website.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you
and you fail to provide that data when requested, we may not be able to perform the contract we
have or are trying to enter into with you (for example, to provide you with goods or services).
In this case, we may have to cancel a product or service you have with us but we will notify you
if this is the case at the time. By way of example, we cannot establish a member account for you
if we do not have your Member Identity Data and we cannot pay out your rewards if we do not have
your Member Reward Payment Data.

Of the types of personal data identified above, Profile Data is personal data you provide to us
entirely at your option, but it will make a significant difference to your experience whilst
using our website and services. In particular, the quality and appropriateness of the Offers
that we send to you are considerably enhanced the more Profile Data we hold about you. You will
still receive Offers even if you choose not to provide us with Profile Data, but you should be
aware these Offers will not have been tailored to suit your personal preferences if we do not
hold sufficient Profile Data and so you may not find them appropriate or be able to qualify for
the same sort of rewards for everything we send to you. You are always in control of how much or
how little Profile Data we hold about you as this is an area of your member’s account
which you can alter at any time, correcting, updating or removing your Profile Data as you
choose.

III. HOW IS YOUR PERSONAL DATA COLLECTED?

Data Collection

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Member Identity, Member Contact and Member
Reward Payment Data by filling in forms or by corresponding with us via our website or by
phone, email or otherwise. This includes personal data you provide when you:

create a membership account on our website;

subscribe to our service or publications;

request marketing to be sent to you;

enter a competition, promotion or survey; or

give us some feedback.

Automated technologies or interactions. As you interact with our website, we may
automatically collect Technical Data about your equipment, browsing actions and patterns. We
collect this personal data by using cookies, server logs and other similar technologies. We
may also receive Technical Data about you if you visit other websites employing our cookies.
Please see the section below on our use of cookies for
further details.

Membership checks from other advertisers. We may receive parts of your Member
Identity Data such as your email address from third party advertisers wishing us to check
whether you are already a member of our website. This is only used to ensure you do not
receive repeat Offers from us because you are already a member with an account on our
website.

IV. HOW WE USE YOUR PERSONAL DATA

Data Usage

We will only use your personal data when the law allows us to. Most commonly, we will use your
personal data in the following circumstances:

Performance of Contract - Where we need to perform the contract we are about to enter
into or have entered into with you.

Legitimate Interest - Where it is necessary for our legitimate interests (or those of
a third party) and your interests and fundamental rights do not override those interests. We
make sure we consider and balance any potential impact on you (both positive and negative)
and your rights before we process your personal data for our legitimate interests. We do not
use your personal data for activities where our interests are overridden by the impact on
you (unless we have your consent or are otherwise required or permitted to by law).

Comply with a legal or regulatory obligation - Where we need to comply with a legal
or regulatory obligation that we are subject to.

Consent - Where you have explicitly consented to us doing so in the way we will
explain below. Consent is only used as a legal basis for our processing in relation to:

how we use your Profile Data. Profile Data is information which we don’t have to
have in order to run your member account, but it makes a very big difference to your
experience of our services if you do choose to provide us with it and in doing so
give your consent to how we use it. We’ll explain more
here; and

use of the search engine facility on our website. By electing to proceed with a
search and by clicking the “search” button, you give your express
consent to the use of Technical Data and Usage Data in returning search results to
match your search terms. We’ll explain more
here.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your
personal data, and which of the legal bases we rely on to do so. We have also identified what
our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the
specific purpose for which we are using your data. Please
contacts us if you need details about the specific
legal ground we are relying on to process your personal data where more than one ground has been
set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

Purpose/Activity

To register you as a new member

Type of data

(a) Member Identity Data

(b) Member Contact Data

Lawful basis for processing including basis of legitimate interest

Performance of a contract with you

Purpose/Activity

To process and deliver your request for membership reward services including to manage
payments of your member rewards

Type of data

(a) Member Identity Data

(b) Member Contact Data

(c) Member Reward Payment Data

(d) Transaction Data

Lawful basis for processing including basis of legitimate interest

(a) Performance of a contract with you

(b) Necessary for our legitimate interests

Purpose/Activity

To manage our relationship with you which will include notifying you about changes to
our terms or Privacy and Cookie Policy in the event of a fundamental change

Type of data

(a) Member Identity Data

(b) Member Contact Data

Lawful basis for processing including basis of legitimate interest

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to
study how members use our services)

Purpose/Activity

To enable you to partake in Offers

Type of data

(a) Member Identity Data

(b) Member Contact Data

Lawful basis for processing including basis of legitimate interest

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our
services, to develop them and grow our business)

Purpose/Activity

To email potential new members that you identify as part of our Member Referral scheme

Type of data

Data you provide to us as a Member Referral

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to provide you with correct credit for making a
referral as a means of growing our membership)

Purpose/Activity

To administer and protect our business and this website (including troubleshooting, data
analysis, testing, system maintenance, support, reporting and hosting of data) and to
provide you with access to support through our Live Chat facility

Type of data

(a) Member Identity Data

(b) Member Contact Data

(c) Technical Data

Lawful basis for processing including basis of legitimate interest

(a) Necessary for our legitimate interests (for running our business, provision
of administration and IT services, network security, to prevent fraud and in the
context of a business reorganisation or group restructuring exercise and for
identifying concerns or issues raised by a member during use of our Live Chat
facility)

(b) Necessary to comply with a legal obligation

Purpose/Activity

To use data analytics to improve our website, Offers/services, marketing, member
relationships and experiences

Type of data

(a) Technical Data

(b) Usage Data

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to define types of member for our Offers and
services, to keep our website updated and relevant, to develop our business and to
inform our marketing strategy)

Purpose/Activity

To deliver relevant website content and targeted member Offers or advertisements to you
and measure or understand the effectiveness of the member Offers or advertisements we
provide to you

Type of data

(a) Member Identity Data

(b) Member Contact Data

(c) Usage Data

(d) Marketing and Communications Data

(e) Technical Data

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to study how members use our products/services,
to develop them, to grow our business and to inform our marketing strategy)

Purpose/Activity

To make suggestions and recommendations to you about Offers or services that may be of
interest to you

The purpose of profiling your preferences from your Profile Data in order for us to
provide a more tailored service to you for each of the purposes:

(a) To deliver relevant website content and targeted Offers or advertisements to
you and measure or understand the effectiveness of the Offers or advertisements
we provide to you

(b) To make suggestions and recommendations to you about Offers or services that
may be of interest to you

Type of data

Profile Data

Lawful basis for processing including basis of legitimate interest

(a) Necessary for our legitimate interests (to tailor our Offers and services
and grow our business) – only when used in a depersonalised or pseudonymised
form, that means we only use it under this condition if your Profile Data can be
separated from any information from which you are personally identifiable and so
can be processed as Anonymous Data

(b) Consent – your Profile Data which is personally identifiable or when used
together with other data which is personally identifiable will only be used for
these purposes with your specific consent. You may choose to update, amend or
remove your Profile Data at any time using our Profile Dashboard which will give
you control over the consent you give us to use this specific Profile Data at
all times.

Purpose/Activity

To share your Profile Data with Named Market Research Partners (see definition of who
this is listed below) for them to
identify suitable targeted Offers to send to you

Type of data

Profile Data

Lawful basis for processing including basis of legitimate interest

Consent – your Profile Data which is personally identifiable or when used together with
other data which is personally identifiable will only be shared with third parties for
these purposes with your specific consent. You may choose to update, amend or remove
your Profile Data at any time using our Profile Dashboard which will give you control
over the consent you give us to use this specific Profile Data at all times.

Purpose/Activity

To deliver search results which match search terms you enter into the search engine
facility on our website

Type of data

(a) Usage Data

(b) Technical Data

Lawful basis for processing including basis of legitimate interest

Consent – your Usage Data and Technical Data which is personally identifiable or when
used together with other data which is personally identifiable will only be shared with
third parties for these purposes with your specific consent. Your consent is provided
when you click the “search” button on our website.

Profiling and Consent

Being an InboxPounds® member is all about you receiving great opportunities to earn
rewards through our membership service. We will still send you Offers, even if you don’t
provide us with any Profile Data, so if you don’t want to fill in those details you still get
the chance to earn cash rewards with InboxPounds®.

However, the best way to get the most out of your membership with InboxPounds® and to
earn more cash rewards, is if we can use the Profile Data that you provide to us in order to
make sure we only send you the particular Offers that we think will suit you the best. We use
Profile Data to learn about your personal preferences and interests and this will determine
which Offers we send to you – this is a largely automated process known as profiling. The only
decisions that our profiling methods make about you and your personal information is to
determine what type of Offers you are most likely to want to see from us given your personal
preferences and demographic information. Our profiling methods do not get used for any other
purpose than to give you great Offers and improve our service to you.

We strive to provide you with choices regarding certain personal data uses, particularly around
the type of Offers, marketing and advertising that you see when you visit our website or receive
opportunities to earn cash rewards with us. With this in mind, we have established our Profile
Dashboard where you can view and make certain decisions about your personal data use.

You are always in control of the amount of personal information which you give to us on your
Profile Dashboard. By completing information in the Profile Dashboard you are giving us your
consent to the use we’re describing in this section of the Privacy and Cookie Policy. You can
remove information you previously provided in the Profile Dashboard at any time to withdraw your
consent (opt out) to your Profile Data being used in this way.

You can also make specific choices about whether you consent to your Profile Data being shared
with third parties for the purposes of matching their Offers to your personal preferences. On
the Profile Dashboard you’ll find a clear box which you can tick if you are happy for us
to share your Profile Data only with those Named Market Research Partners which are specifically
listed below. You can untick this box at any
time to withdraw your consent (opt out) to your Profile Data being shared with the Named Market
Research Partners.

Search Engine and Consent

When you are using our website you may wish to use the search engine facility to find something
in particular on the website. If you do decide to use this facility you should be aware that
this part of our website is made available using one of our external third party providers
called System1 LLC, who provide search engine facilities, and that when they undertake a search
they will in turn transfer the data used to other third party providers such as Microsoft and
Google.

If you give your consent by clicking on the “search” button on our website then
System1 LLC will have access to your Usage Data and Technical Data. They will only have access
to the Usage Data and Technical Data which is necessary for the purpose of matching search
results to the search terms that you’ve entered into the search facility. To carry out
this service there is interaction by System1 LLC with Google and Microsoft functionality to
allow matching search results to be returned to you.

System1 LLC will only use your Usage Data and Technical Data in accordance with their own
Privacy Policy and that Privacy Policy also gives you an explanation of how System1 LCC will
use and transfer data to Microsoft and Google: http://system1.com/terms/privacy-policy

You are always in control of the amount of personal information which you give to us when using
our website and using the search engine facility is no different. By using the search engine
you are giving us your consent only to the data transfers and use we’re describing in this
section of the Privacy and Cookie Policy. You can withdraw your consent by stopping using the
search engine at any time and System1 LLC or any of the third parties to which they transfer
your Usage Data and Technical Data will no longer have access to it.

V. COOKIES

About Cookies and Third Party Technology.

A “cookie” is a small data file that may be saved to and stored on your computer
when you visit a website or open an email. Cookies are widely used in order to make websites
work, or work more efficiently, as well as to provide information to the owners of the site.
Cookies permit a website to “remember” whether your computer has visited the website
before and helps the website create a more personalised experience for you and records
activities taken by you, such as Offers completed. In this way cookies also allow us to verify
the identity of a new member registration to ensure it matches the details of a Member Referral
and so allow us to credit you with additional rewards for making that Member Referral.

For a full list of all cookies used on our website, please follow this link to
cookie information.

In addition to cookie technology, InboxPounds® use additional third party technology and
tracking tools to record Offers and activities completed by you, friends referred by you, and to
communicate information about you, such as anonymised demographic information (e.g., age,
gender), in order to target Offers and advertisements to specific groups as requested by
advertisers. Cookies and other tracking technology are collectively referred to as
“Cookies and Recording Tools”.

Your computer permits you to change the settings on your web browser to not accept and/or
disable Cookies and Recording Tools. However, if you do not accept Cookies and Recording Tools
used by InboxPounds®, you may not be able to use certain functions on the website or on
certain links to external websites. More importantly, if you do not accept Cookies and Recording
Tools you will not receive credit for Offers or other actions completed by you because we are
unable to track and record your activity. If you do not want to accept Cookies and Recording
Tools, you must stop using this website.

Also remember that any time you leave our website using a link to a third party’s website,
such as one of the advertisers or partners who have links and adverts on our website, they may
also use cookies. So make sure you visit their cookie policy to ensure you are comfortable with
how they do things once you have left our website.

Except for essential cookies, all cookies will expire after the period of time provided
here.

Referral and Affiliate Tracking

InboxPounds® uses cookies in order to collect Transaction Data which allows us to track
new Member registrations. This ensures Members are properly credited for referring other
Members, as well as to track the rewards you’ve earned by completing Offers which have
connected you to our advertisers and partners.

Member Recognition

After you have logged on as a Member into the InboxPounds® Member’s Section,
cookies are used to remember your Member name and password so they do not need to be entered
during every visit to our website. You can logout of the Member’s Section if you do not
wish to have this information saved.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we
reasonably consider that we need to use it for another reason and that reason is compatible with
the original purpose. If you wish to get an explanation as to how the processing for the new
purpose is compatible with the original purpose, please
contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will
explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in
compliance with the above rules, where this is required or permitted by law.

VI. DISCLOSURES OF YOUR PERSONAL DATA

About Disclosure

We may have to share your personal data with the parties set out below for the purposes set out
in the table in paragraph 4 above.

Internal Third Parties being other companies in the CotterWeb Group – As explained
above, InboxPounds® Limited and CotterWeb Enterprises Inc. are the two companies in
the CotterWeb Group and each of these companies is a joint controllers, together being
responsible for processing your data.

External Third Parties could be any of the following:

Professional advisers including lawyers, bankers, auditors and insurers based either
in the UK or the US who provide consultancy, banking, legal, insurance and
accounting services to the CotterWeb Group.

HM Revenue & Customs, regulators and other authorities based in the UK who
require reporting of processing activities in certain circumstances.

Our third party service providers and business partners who assist with the running
of the website and our Offers, services and products including hosting providers,
payment processing partners, software service providers and backup and support
services providers. Our third party service providers and business partners are
subject to security and confidentiality obligations and are only permitted to
process your personal information for specified purposes and in accordance with our
instructions.

System1 LLC who provide search engine facilities on our website. As part of this
service there is interaction with Google and Microsoft functionality to allow
search results to be returned which match the search terms you enter on our website.
An explanation of how System1 LCC will use and transfer data to Microsoft and Google
is set out in System1 LLC’s privacy policy, a link to which is set out below.
If you do not wish for your data to be used and transferred in this manner then
please do not use the search engine. http://system1.com/terms/privacy-policy

Named Market Research Partners – those market research partners with which
CotterWeb Group has an existing relationship and which are named on the Profile
Dashboard so you can specifically choose whether or not you consent to your Profile
Data being shared with these Named Market Research Partners and whether you wish to
remove your consent at any time (which, if you do, we will ensure means your Profile
Data is removed from our records within a reasonable time from your request and that
this withdrawal of consent is also passed on to the Named Market Research Partners
so that they stop using the Profile Data that we have shared with them previously).
The Named Market Research Partners are shown below together with links to their own
privacy policies:

Third parties to whom we may choose to sell, transfer, or merge parts of our
business or our assets. Alternatively, we may seek to acquire other businesses or
merge with them. If a change happens to our business, then the new owners may use
your personal data in the same way as set out in this Privacy and Cookie Policy.

We require all third parties to respect the security of your personal data and to treat it in
accordance with the law. We do not allow our third-party service providers to use your personal
data for their own purposes and only permit them to process your personal data for specified
purposes and in accordance with our instructions.

VII. SOCIAL MEDIA AND ONLINE ENGAGEMENT

Social Media

We occasionally use a variety of new technologies and social media options to communicate and
interact with our members. These sites and applications include popular social networking and
media sites. To better engage the public in ongoing dialog, we use certain third-party platforms
including, but not limited to, Facebook and Twitter. These third-party websites and applications
are web-based technologies that are not exclusively operated or controlled by us. When
interacting on those websites, you may reveal certain personal information to us or to third
parties. Other than when used by our employees for the purpose of responding to a specific
message or request, we will not use, share, or retain your personal information.

VIII. INTERNATIONAL TRANSFERS

International Transfer of Data

We share your personal data within the CotterWeb Group. This will involve transferring your data
outside the EEA.

Many of our External Third Parties are based outside the EEA so their processing of your
personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection
is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an
adequate level of protection for personal data by the European Commission.

Where we use certain service providers, we may use specific contracts approved by the
European Commission which give personal data the same protection it has in Europe.

Where we use providers based in the US, we may transfer data to them if they are part of the
Privacy Shield which requires them to provide similar protection to personal data shared
between the Europe and the US.

Please contact us if you want further information on
the specific mechanism used by us when transferring your personal data out of the EEA.

IX. DATA SECURITY

About Data Security

We have put in place appropriate security measures to prevent your personal data from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition,
we limit access to your personal data to those employees, agents, contractors and other third
parties who have a business need to know. They will only process your personal data on our
instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify
you and any applicable regulator of a breach where we are legally required to do so.

X. DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we
collected it for, including for the purposes of satisfying any legal, accounting, or reporting
requirements.

By law and in order to answer any member payment queries or respond to any claims regarding
payments made, we have to retain a record of some of the basic information about our customers
(including Member Identity Data, Member Contact Data and Member Reward Payment Data) for seven
years after they cease being members for these accounting and tax purposes. This record of
historic payments we have made to you and the account to which those payments relate are kept
separately from details of all other elements of your member account once your account is no
longer active. This information is secured and access is further restricted to ensure these
records are not used for any other purposes than to respond to such legal, accounting, tax and
any other related payment queries or claims if necessary.

In all other respects, the personal data that you provide to us will only be retained for the
life of your member account being active. If your member account is inactive for 6 months, the
Member Identity Data, Member Contact Data and Member Reward Payment Data will be deleted from
our member records databases and replaced with a string of numbers which means all other
information such as any Transaction Data, Technical Data or Profile Data can no longer be
re-associated with your personal information. Following a further period of 7 days, after which
our back up facilities are overwritten, the only information retained relating to your member
account will then permanently be Anonymous Data. Once it has become Anonymous Data (so that it
can no longer be associated with you) your information will be retained indefinitely for
research and statistical purposes without further notice to you.

In some circumstances you can ask us to delete your data: see
Request erasure below for further information.

XI. YOUR LEGAL RIGHTS UNDER GDPR (For EU Individuals)

About your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your
personal data. You have the right to:

Request access to your personal data (commonly known as a “data subject access
request”). This enables you to receive a copy of the personal data we hold about you and
to check that we are lawfully processing it.

You will not have to pay a fee to access your personal data (or to exercise any of the other
rights). However, we may charge a reasonable fee if your request is clearly unfounded,
repetitive or excessive. Alternatively, we may refuse to comply with your request in these
circumstances.

We may need to request specific information from you to help us confirm your identity and ensure
your right to access your personal data (or to exercise any of your other rights). This is a
security measure to ensure that personal data is not disclosed to any person who has no right to
receive it. We may also contact you to ask you for further information in relation to your
request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us
longer than a month if your request is particularly complex or you have made a number of
requests. In this case, we will notify you and keep you updated.

Request correction of the personal data that we hold about you. This enables you to have
any incomplete or inaccurate data we hold about you corrected, though we may need to verify the
accuracy of the new data you provide to us. With InboxPounds® and our My Account page
you are always in control of the information we hold about you and so can ensure it is correct
and accurate yourself at any time.

Request erasure of your personal data. This enables you to ask us to delete or remove
personal data where there is no good reason for us continuing to process it. You also have the
right to ask us to delete or remove your personal data where you have successfully exercised
your right to object to processing (see below), where we may have processed your information
unlawfully or where we are required to erase your personal data to comply with local law. Note,
however, that we may not always be able to comply with your request of erasure for specific
legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest
(or those of a third party) and there is something about your particular situation which makes
you want to object to processing on this ground as you feel it impacts on your fundamental
rights and freedoms. You also have the right to object where we are processing your personal
data for direct marketing purposes. In some cases, we may demonstrate that we have compelling
legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to
suspend the processing of your personal data in the following scenarios: (a) if you want us to
establish the data’s accuracy; (b) where our use of the data is unlawful but you do not
want us to erase it; (c) where you need us to hold the data even if we no longer require it as
you need it to establish, exercise or defend legal claims; or (d) you have objected to our use
of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to
you, or a third party you have chosen, your personal data in a structured, commonly used,
machine-readable format. Note that this right only applies to automated information which you
initially provided consent for us to use or where we used the information to perform a contract
with you.

Withdraw consent (opt out) at any time where we are relying on consent to process your
personal data. However, this will not affect the lawfulness of any processing carried out before
you withdraw your consent. If you withdraw your consent, we may not be able to provide certain
products or services to you and neither will the Named Market Research Partners who have also
relied on your consent to process the Profile Data we have shared with them. We will advise you
if this is the case at the time you withdraw your consent.

The right to file a complaint with your regional Data Protection Authority regarding the
handling of your personal data by us. Please go to this list of Data Protection Authorities to locate contact information for your DPA.

If you wish to exercise any of the rights set out above, please
contact us.

Privacy Shield

The EU has established strict protections regarding the handling of personally identifiable
information that is received in the US from the EU (“EU Personal Data”) and
this includes requirements to provide adequate protection for that EU Personal Data.

CotterWeb Enterprises, Inc. is subject to the regulatory and enforcement authority of the US
Federal Trade Commission.

CotterWeb Enterprises, Inc. complies with the EU-US Privacy Shield Framework as set forth by the
US Department of Commerce regarding the collection, use, and retention of personal information
from European Union member countries transferred to the United States pursuant to Privacy
Shield. CotterWeb Enterpries Inc. has certified that it adheres to the Privacy Shield Principles
with respect to such data. If there is any conflict between the policies in this privacy policy
and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall
govern. To learn more about the Privacy Shield program, and to view our certification page,
please visit https://www.privacyshield.gov/

Pursuant to the Privacy Shield we are required to notify those members from the EU that we may
be compelled to release their EU Personal Data in response to lawful requests by public
authorities including to meet national security and law enforcement requirements.

We acknowledge the right of those members from the EU about whom we process EU Personal Data to
access their personal data pursuant to the Privacy Shield. Individuals wishing to exercise this
right may do so by contacting CotterWeb Enterprises Inc. at the contact details provided below.
As an organization which is compliant with the Privacy Shield Principles, CotterWeb Enterprises
Inc. remains liable for the processing of the EU Personal Data by a third party acting on our
behalf, unless we can prove we were not a party to the actions giving rise to the damage.

EU individuals can, under the Privacy Shield, control whether their personal information is to
be disclosed to a third party or to be used for a purpose that is materially different from the
purpose for which it was originally collected or subsequently authorized by that individual.
Prior to filling out the Profile Survey, consent is requested to authorize the disclosing your
information. If we need to use your personal data for a purpose that is materially different
from the purpose(s) for which you have previously provided consent, we will notify you and we
will explain the legal basis which allows us to do so. If you wish to opt out of our use of your
data in this way, you may withdraw consent (opt out) at any time by visiting the
My Account page.

In compliance with the Privacy Shield Principles, CotterWeb Enterprises Inc. commits to resolve
complaints about your privacy and our collection or use of your personal information transferred
to the United States pursuant to Privacy Shield. European Union individuals with Privacy Shield
inquiries or complaints should first contact CotterWeb Enterprises Inc. at:

Name or title of DPO: Chief Technical Officer, Tom Healy

Email address: dpo@cotterweb.net

Telephone number: 651 289 0720

CotterWeb Enterprises Inc. has further committed to refer unresolved privacy complaints under
the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY
SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely
acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please
visit here
for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain
conditions, you may invoke binding arbitration for some residual claims not resolved by other
redress mechanisms. See Privacy Shield Annex 1

General Terms & Conditions & Privacy Policy

The acceptance of both the Privacy Policy and the Terms & Conditionsare required for membership.